- Portfolio Resources Group fined $100k, and to meet AML compliance standards.
- AML compliance officer or his designee would manually monitor account activity.
- The firm also used a system that provided alerts to assist in its AML monitoring.
- AML systems failed to identify, transactions that should have triggered red flags.
- Significant portion of their customers were from particular country and engaged
in activity in their firm accounts that would be more indicative of bank accounts.
- Policy was not tailored, to the risks associated with this type of account activity.
Compliance Policy Gaps
- Policy stated AML compliance officer would manually monitor sufficient amount
of account activity, to allow it to identify suspicious activity, and then file SARs.
- Utilized system that provided alerts to assist in monitoring for AML compliance.
- However failed to identify or document detection, investigation of due diligence
of suspicious trades by customer that involved high levels of money movement.
- Little or no corresponding securities trades that should have triggered red flags.